The Catholic University of America

Responsibilities of the Radiation Safety Officer

Radioactive Material Storage (Atomic Energy Act) and Increased Controls for Radioactive Material Quantities of Concern (NRC Order EA 05-090)

If licensed to possess radioactive material, the University must:

Secure any licensed material stored in controlled or unrestricted areas against unauthorized removal or access, and

Control and maintain constant surveillance of licensed material that in controlled or unrestricted areas and that is not in storage

If the Nuclear Regulatory Commission (NRC) issues an order to the University regarding radioactive materials or devices kept in "quantities of concern," the University must implement increased controls as follows:

Only "trustworthy" and "reliable" persons allowed unescorted access, and anyone with unescorted access must be fingerprinted and undergo an FBI background check.  “Trustworthy and reliable” are determined by verification of employment history, education, and personal references.

The University must have a documented program to monitor and immediately detect, assess and respond to unauthorized access.

Portable or mobile devices must have 2 independent physical controls that form tangible barriers to secure against unauthorized removal.

Required documentation under the order must be treated as sensitive information, and must be kept for 3 years after no longer effective. 

The import or export of nuclear equipment or material requires a special license issued by the NRC.  Retransfers require authorization by the Department of Energy. The University must notify the NRC regarding regulated activities that have significant implication for public health/safety or common defense or security.  Transport of quantities of concern requires that the University as the licensee:

Use a carrier that utilizes a package tracking system, has a system to assure driver trustworthiness and reliability, and has the capability for immediate communication to summon assistance or response

Contact the recipient to coordinate expected arrival and confirm its receipt

Investigate delayed shipment

Provide 90 days advanced notice to NRC if the material exceeds 100 times the threshold quantity of concern

The Radiation Safety Officer, working in conjunction with the Director of EH&S, is responsible for implementing monitoring, security, transport and other internal controls pertaining to radioactive materials and, if applicable, those that qualify as “quantities of concern.”

Related Policies

Contractor Safety Guide

Environmental Health and Safety Manual

Environmental Health and Safety (website)

Laboratory Security Policy

Radiation Safety Manual

Safety and Protection of the Environment Policy